CARDIOLOGY ASSOCIATES PRIVATE LIMITED
PERSONAL DATA PROTECTION ACT

THE PERSONAL DATA PROTECTION ACT

THE PERSONAL DATA PROTECTION ACT (ACT NO. 12 OF 2012) (“PDPA”) REGULATES THE COLLECTION, USE AND DISCLOSURE OF AN INDIVIDUAL’S PERSONAL DATA. THE GENERAL RULE LAID OUT BY THE LEGISLATION IS THAT PERSONAL DATA CAN ONLY BE COLLECTED, USED AND/OR DISCLOSED WITH THE CONSENT OF THE INDIVIDUAL CONCERNED.

CAPL IS LIABLE FOR ALL THE ACTS COMMITTED BY ITS EMPLOYEES, UNLESS REASONABLE STEPS HAVE BEEN TAKEN BY CAPL TO PREVENT THEM FROM VIOLATING THE ACT.

THIS POLICY THEREFORE AIMS TO INFORM THE GENERAL PUBLIC ABOUT HOW CAPL COMPLIES WITH THE PDPA. IT ALSO PROVIDES A SET OF PRACTICAL STEPS THAT PEOPLE MAY TAKE TO GAIN ACCESS TO, OR MAKE CORRECTIONS TO THEIR PERSONAL DATA PROVIDED TO CAPL. THESE STEPS ALSO ALLOW THEM TO WITHDRAW THEIR CONSENT TO THE COLLECTION, USE OR DISCLOSURE OF THEIR PERSONAL DATA.

1. PERSONAL DATA

IN THIS DATA PROTECTION POLICY (“POLICY”) AND UNDER THE PDPA, “PERSONAL DATA” REFERS TO ANY DATA (WHETHER TRUE OR NOT) ABOUT AN INDIVIDUAL WHO CAN BE IDENTIFIED [1] FROM THAT DATA; OR [2] FROM THAT DATA AND OTHER INFORMATION TO WHICH WE HAVE OR ARE LIKELY TO HAVE ACCESS.

EXAMPLES OF SUCH PERSONAL DATA MAY INCLUDE A PERSON’S:

  • NAME, NRIC, PASSPORT OR OTHER IDENTIFICATION NUMBER; DATE OF BIRTH;
  • CONTACT DETAILS SUCH AS TELEPHONE NUMBER(S), MAILING ADDRESS(ES), AND EMAIL ADDRESS(ES);
  • BASIC MEDICAL INFORMATION (E.G. DRUG OR FOOD ALLERGY);
  • IMAGES;
  • EMPLOYMENT AND FINANCIAL DETAILS; OR
  • ANY OTHER INFORMATION RELATING TO ANY INDIVIDUALS WHICH MAY HAVE BEEN PROVIDED TO CAPL, IN ANY FORM.


IN THIS POLICY, “WE”, “US”, “OUR” OR “CAPL” REFERS TO CARDIOLOGY ASSOCIATES PRIVATE LIMITED, “YOU”, “YOUR” OR “YOURS” REFERS TO THE PERSONS TO WHOM THIS POLICY APPLIES.


2. COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA

CAPL IS COMMITTED TO ADHERING TO ITS LEGAL OBLIGATIONS UNDER THE PDPA. THIS MEANS THAT CAPL WILL DO ITS BEST TO COMPLY WITH THE GENERAL RULE LAID OUT BY THE PDPA THAT PERSONAL DATA CAN ONLY BE COLLECTED, USED AND/OR DISCLOSED WITH THE CONSENT OF AN INDIVIDUAL (SUBJECT TO THE EXCEPTIONS AND ON THE TERMS PROVIDED IN THE PDPA).

NOTE: THE INFORMATION IN THIS POLICY MERELY PROVIDES AN OVERVIEW OF CAPL’S OBLIGATIONS UNDER THE PDPA. THIS POLICY IS NOT A REPRESENTATION BY CAPL THAT IS MEANT TO CREATE ANY PRIVATE LAW OBLIGATION. CAPL’S PRECISE LEGAL OBLIGATIONS MAY BE FOUND IN THE PDPA, THE PERSONAL DATA PROTECTION REGULATIONS 2014 AND ANY OTHER SUBSIDIARY REGULATIONS, NOTICES OR GUIDELINES IN FORCE. CAPL MAY, FROM TIME TO TIME, UPDATE THIS POLICY TO REFLECT ANY CHANGES IN LEGAL OR REGULATORY REQUIREMENTS.

  • IN GENERAL, CAPL COLLECTS PERSONAL DATA WHEN:
  • YOU SUBMIT ANY FORM (SUCH AS REGISTRATION, DRIVING LICENSE RENEWAL APPLICATION, MEDICAL DOCUMENTS, LABORATORY RESULTS, X-RAY REPORTS, CONSENT ETC);
  • YOU PROVIDE OTHER DOCUMENTATION OR INFORMATION IN RESPECT OF YOUR INTERACTIONS AND TRANSACTIONS WITH CAPL, OR WHEN YOU USE CAPL’S SERVICES;
  • YOU INTERACT WITH CAPL STAFF, AND OTHER REPRESENTATIVES (FOR EXAMPLE, VIA TELEPHONE CALLS, EMAIL, FAX, LETTERS, FAX, AND FACE-TO-FACE MEETINGS);
  • YOU REQUEST THAT CAPL CONTACT YOU, OR BE INCLUDED IN AN EMAIL LIST KEPT BY CAPL;
  • YOU RESPOND TO CAPL’S REQUEST FOR ADDITIONAL PERSONAL DATA THROUGH OTHER INITIATIVES;
  • YOU SUBMIT AN EMPLOYMENT OR OBSERVER / HELPER APPLICATION, OR WHEN YOU PROVIDE DOCUMENTS OR INFORMATION INCLUDING YOUR RESUME AND/OR CURRICULUM VITAE IN CONNECTION WITH ANY REQUEST;
  • YOUR IMAGES ARE CAPTURED BY US VIA CCTV CAMERAS WHILE YOU ARE WITHIN OUR PREMISES, OR VIA PHOTOGRAPH TAKEN BY US;
  • CAPL SEEKS INFORMATION ABOUT YOU AND RECEIVES YOUR PERSONAL DATA IN CONNECTION WITH YOUR RELATIONSHIP WITH CAPL INCLUDING FOR OUR PRODUCTS AND SERVICES OR JOB APPLICATIONS, FOR EXAMPLE, FROM CURRENT / FORMER EMPLOYERS OR THE RELEVANT AUTHORITIES; AND/OR
  • YOU SUBMIT YOUR PERSONAL DATA TO CAPL FOR ANY OTHER REASON.

ACCURACY
: CAPL WILL MAKE REASONABLE EFFORTS TO ENSURE THAT THE PERSONAL DATA CAPL COLLECTS IS ACCURATE AND COMPLETE. PLEASE HELP CAPL BY ENSURING THAT ALL PERSONAL DATA THAT YOU SUBMIT IS COMPLETE AND ACCURATE. IF YOU FAIL TO DO SO, CAPL MAY BE UNABLE TO PROVIDE YOU WITH THE SERVICES YOU HAVE REQUESTED.

IF CAPL IS LIKELY TO USE YOUR PERSONAL DATA TO MAKE A DECISION THAT AFFECTS YOU, OR IF WE HAVE TO DISCLOSE YOUR PERSONAL DATA TO ANOTHER ORGANISATION, CAPL WILL MAKE REASONABLE EFFORTS TO ENSURE THAT PERSONAL DATA COLLECTED BY OR ON BEHALF OF US IS ACCURATE AND COMPLETE.

SECURITY: CAPL WILL PROTECT THE PERSONAL DATA BY MAKING REASONABLE SECURITY ARRANGEMENTS. HOWEVER, CAPL CANNOT COMPLETELY GUARANTEE THE SECURITY OF YOUR PERSONAL DATA.


3. PURPOSES OF COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA


IN GENERAL, CAPL MAY COLLECT, USE AND DISCLOSE PERSONAL DATA FOR THE FOLLOWING PURPOSES, AMONGST OTHERS:

  • RESPONDING TO, PROCESSING AND HANDLING APPOINTMENTS, QUERIES, REQUESTS, FEEDBACK AND SUGGESTIONS;
  • ASSISTING AND CONTACTING PARTIES IN RELATION TO THE SERVICES THEY HAVE REQUESTED;
  • CONTACTING PARTIES IN RELATION TO EVENTS CAPL IS HOSTING;
  • RESEARCH IN RELATION TO MEDICALLY RELATED ISSUES;
  • TO PROVIDE INFORMATION TO THE RELEVANT FUNDING AGENCIES;
  • TO REFER INDIVIDUALS TO MINISTRY OF HEALTH HEALTHCARE FACILITIES;
  • CAPL’S INTERNAL RECORD KEEPING PURPOSES;
  • CONTACTING INDIVIDUALS REGARDING THEIR REST RESULTS OR APPOINTMENTS; OR
  • COMPLYING WITH ANY APPLICABLE RULES, LAWS AND REGULATIONS, CODES OF PRACTICE OR GUIDELINES OR TO ASSIST IN LAW ENFORCEMENT AND INVESTIGATIONS BY RELEVANT AUTHORITIES.

CAPL WILL SEEK YOUR PRIOR CONSENT FOR ANY DISCLOSURE OF YOUR PERSONAL INFORMATION IN RELATION TO ANY OTHER PURPOSE THAT IS NOT LISTED ABOVE.

CAPL WILL RETAIN YOUR PERSONAL DATA FOR AS LONG AS THE PURPOSE(S) FOR WHICH IT WAS COLLECTED REMAIN(S) VALID, OR FOR AS LONG AS THE PERSONAL DATA IS NECESSARY FOR CAPL’S LEGAL OR BUSINESS PURPOSES.


4. CONTACTING CAPL: FEEDBACK, COMPLAINTS, ACCESS AND CORRECTION OF YOUR PERSONAL DATA, AND WITHDRAWAL OF CONSENT

IF YOU:

  • HAVE ANY QUESTIONS OR FEEDBACK ABOUT HOW CAPL HANDLES PERSONAL DATA;
  • HAVE ANY COMPLAINTS ABOUT HOW CAPL HAS HANDLED YOUR PERSONAL DATA;
  • WISH TO OBTAIN ACCESS OR MAKE CORRECTIONS TO YOUR PERSONAL DATA THAT CAPL HAS; OR
  • WISH TO WITHDRAW YOUR CONSENT TO CAPL’S USE OF YOUR PERSONAL DATA,

YOU MAY CONTACT CAPL’S DATA PROTECTION OFFICER:

NAME: DR LIM YEAN TENG
EMAIL: ENQUIRY@HEARTSPECIALIST.COM.SG

PLEASE IDENTIFY YOURSELF AND INDICATE THE PERSONAL DATA THAT THE REQUEST CONCERNS. CAPL WILL STRIVE TO RESPOND TO EACH REQUEST AS SOON AS REASONABLY POSSIBLE AND AS ACCURATELY AND COMPLETELY AS NECESSARY. HOWEVER, PLEASE NOTE THAT CAPL MAY REFUSE YOUR REQUEST UNDER CERTAIN CIRCUMSTANCES AS LAID OUT UNDER THE PDPA.

NOTE ON WITHDRAWAL OF CONSENT: IF YOU WITHDRAW YOUR CONSENT TO ANY OR ALL USE OF YOUR PERSONAL DATA, DEPENDING ON THE NATURE OF YOUR REQUEST, CAPL MAY NOT BE ABLE TO CONTINUE PROVIDING ITS SERVICES OR PERFORMING ITS CONTRACTUAL OBLIGATIONS TO YOU. ANY WITHDRAWAL OF CONSENT MAY ALSO RESULT IN THE TERMINATION OF ANY AGREEMENTS OR ARRANGEMENTS YOU HAVE WITH CAPL AND YOU BEING IN BREACH OF YOUR CONTRACTUAL OBLIGATIONS OR UNDERTAKINGS. CAPL RESERVES ITS LEGAL RIGHTS AND REMEDIES IN SUCH EVENT.